Italy: Mandatory disclosure directive (DAC6), transposition into domestic law

Italy: Mandatory disclosure directive (DAC6)

The Italian government approved a legislative decree to transpose Council Directive (EU) 2018/822 on mandatory disclosure (DAC6) into Italian domestic law.


Related content

The legislative decree is expected to be published in the official gazette and then followed first by a ministerial decree that would clarify certain aspects of DAC6 (such as the hallmarks and main benefit test), and then by a statement of practice from the Italian tax authority concerning the practical reporting requirements.

With the legislative decree, Italy opted for a six-month deferral of the reporting deadlines, as allowed by EU-level amendments to DAC6 in response to the coronavirus (COVID-19) pandemic.

In general, DAC6 extends the scope of application of a mechanism for the automatic exchange of information between EU tax administrations, including information about reportable cross-border arrangements that potentially constitute aggressive tax planning. The scope of the Italian legislative decree aligns with DAC6 and has not been extended to cover value added tax (VAT), customs duties, excise taxes, and compulsory social security contributions.

Read an August 2020 report [PDF 182 KB] prepared by the KPMG member firm in Italy

© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal